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(3) Whether petitioner is liable for an addition to tax for
late filing under section 6651(a). We hold that petitioner is
liable.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated by this reference. Tsai-Hsiu Hsu Yang (Yang), also
known as Tsai-Hsiu Hsu Young, is executrix of the estate
(petitioner) of Wayne-Chi Young, deceased (decedent). Yang was
decedent's wife (collectively the Youngs). At all material
times, Yang and decedent were residents of the State of
California, a community property State. At all times relevant to
this case, neither decedent nor Yang was a citizen of the United
States, but they were residents of the United States.
Decedent died on June 28, 1989. At the time of decedent's
death, the executrix Yang knew that the assets of the estate
exceeded $1,200,000. On March 21, 1990, petitioner filed Form
4768, Application for Extension of Time To File a Return and/or
Pay U.S. Estate (and Generation-Skipping Transfer) Taxes,
requesting an extension of time to file the return and to pay the
estate tax to March 28, 1991. On April 11, 1990, respondent
approved petitioner's application for extension of time to file
and pay. Before March 28, 1991, petitioner filed a second Form
4768, requesting an additional extension to file the return and
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